EPISODE · Jan 23, 2026 · 16 MIN
Substance Called—CRA Wants Its Residual Back: Bill C-15, OECD delineation, and the 30-day documentation squeeze
from The Transfer Pricing Show · host Josh Post
CRA’s been aggressive for years—now Canada wants OECD-style “actual conduct” baked into the statute. Bill C-15 shrinks the doc clock to 30 days and makes “contracts say” a weaker defense when reality says otherwise. If your residual lives offshore but decisions live in Canada, expect the phone to ring.
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Substance Called—CRA Wants Its Residual Back: Bill C-15, OECD delineation, and the 30-day documentation squeeze
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